Detailed Feedback
OEKO-TEX® Public Stakeholder Consultation

Edition 01.2023
OEKO-TEX®
International Association for Research and Testing in
the Field of Textile and Leather Ecology
Internationale Gemeinschaft für Forschung und Prüfung
auf dem Gebiet der Textil- und Lederökologie

OEKO-TEX Service GmbH
Genferstrasse 23, CH-8002 Zurich+41 44 501 26 00
www.oeko-tex.com

Content
1.1. RSL ................................................................................................................................................................... 2
1.2. MRSL ............................................................................................................................................................... 3
1.3. Do you have any other questions or comments concerning the OEKO-TEX® RSL / MRSL? ................................ 4
1.4.1. Have you ever calculated your environmental impact like carbon footprint or water footprint? ...................... 5
1.4.2. How important is carbon and water footprinting for you (and your business)? ............................................... 6
1.4.3. Have a look at our "Impact calculator" - what would be the most important step for you for future
development? ........................................................................................................................................................ 6
2.1. OEKO-TEX® RESPONSIBLE BUSINESS ............................................................................................................ 8
2.2. What information do you find valuable in the label check? Would you like to see any further information
displayed? ............................................................................................................................................................ 10
2.3. OEKO-TEX® MADE IN GREEN ........................................................................................................................ 11
3.1. Circularity ....................................................................................................................................................... 13
3.2. OEKO-TEX® Portfolio and Scope ................................................................................................................... 17

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1II. Updates 2022

1.1. RSLa) Are there chemicals that you would want to see on the OEKO-TEX® RSL? Which ones and why?
Feedback received

Comments

REACTIVE COLORS, EVERY INDUSTRY TEXTILE USED COLORSREACTIVE

Reactive dyes have a certain allergenic potential as dyes, but this is nolonger present after they have reacted, after a covalent bonding tofiber material. Reactive colours are part of the manufacturing audit of
the OEKO-TEX® STeP certification, but is not within the scope of
OEKO-TEX® STANDARD 100 or OEKO-TEX® LEATHER STANDARD
RSL, as the topic is related to process control and not product control.
Therefore, no new reactive dyes will be included in 2023.

Its good.

Thank you for the valuable comment.

No

Thank you for the valuable comment.

No, I have no additions to add.

Thank you for the valuable comment.

No

Thank you for the valuable comment.

No

Thank you for the valuable comment.

No question

Thank you for the valuable comment.

Dioxine / Furanes / PCB
On Baby diapers it's becoming a focus
especially in France (ANSES report)

For the dioxins, furanes and PCB we had been tracking the ANES report
as well and understand the concern. However, since ECHA has reached
the conclusion, not to add the substances for further control we will not
be adding the substances to our RSL but will be keeping a close call on
any upcoming legislation.

Maybe Aziridine crosslinker, its harmfull for production employees.
Yes, it's amongst the best products for our products.

While aziridine does have two relevant toxicities (H340 & H350) the
product, however CO2 in the air is enough for it to polymerize. Since it isvery reactive it is also no longer found on the products. Aziridine
crosslinker are already covered in the manufacturing audit of the
OEKO-TEX® STeP certification but is not within the scope of
OEKO-TEX® STANDARD 100 or OEKO-TEX® LEATHER STANDARD
RSL, as the topic is related to process control and not product control.
Therefore, we will not include aziridine crosslinkers in 2023.

No

Thank you for the valuable comment.

No

Thank you for the valuable comment.

I don't know they are in the list, I'm going to do a research aboutcertified d chemicals and/or company that are certified

We appreciate your efforts. If you have any results of your researchthat you would like to share with us, please feel free to reach out to us.
You can find our contact information on the OEKO-TEX® website:
OEKO-TEX® | Contact us!

b) Are there parameters or limit values you have questions about? Which ones and why?
Feedback received

Edition 01.2023

Comments2

NO

Thank you for the valuable comment.

We trust on the applied criteria.

Thank you for the valuable comment.

noThank you for the valuable comment.

NO

Thank you for the valuable comment.

Organotins limit can be lower (EDANA agreement ppb)

The limit for organic tin compounds is under revision by
OEKO-TEX® and will be brought to a final decision in
Q2/Q3 of 2023

noThank you for the valuable comment.

No question

Thank you for the valuable comment.

Crocktest for window covering products: why such high values for afabric you do not touch?

Assessing each product individually and providing own limit values
would be too complex. Furthermore, it is difficult to predetermine theexact use of the product. Therefore, we must treat them as worst-casescenarios. We will stay with a general limit in our RSL.

no

Thank you for the valuable comment.

No

Thank you for the valuable comment.

PH values for post-consumer textiles. We see in many cases a PH
between 7.5 and 8. Probably due to detergents from washing byconsumers...if this limit value is kept, we foresee many problems incertifying post-consumer recycled textiles (mechanical).

OEKO-TEX® believes that consumer safety is most important. Thisimplies that recycled articles should never contain harmful substances inlarger concentrations compared to virgin certified articles.
OEKO-TEX® is always open for discussion and the topic of recycledmaterials will be further developed within OEKO-TEX®.
Recycled materials must respect the same limit values to get the
OEKO-TEX® STANDARD 100 label as new articles. As such,
OEKO-TEX® STANDARD 100 recycled articles will be tested for
harmful substances that are banned today.

NPEO limit values. There is an exemption in REACH for NPEOs inpost-consumer textiles in some cases. Because they are expected towash out? In any case we see NPEOs come up in post-consumer textiles
from US because there they are not banned and still in many laundry
detergents.
In general, these two cases point at the problem for post-consumer
textiles. With OEKO-TEX® certification the production of textiles canbe controlled, and certain products banned by suppliers that follow
OEKO-TEX® RSL/MRSL. But how does the consumer fit it? If there arestill detergents on the market that affect certain parameters there is no
way to control that now. Also...we can see old items that have chemicals
that weren't banned before (but are now). I urge OEKO-TEX® to lookfurther into this to enable best possible protocol to certify
post-consumer

1.2. MRSLa) Are there additional chemicals that you would want to see on the OEKO-TEX® MRSL? Which ones and why?
Feedback received

Comments

NO

Thank you for the valuable comment.

No mayor comments

Thank you for the valuable comment.

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3

noThank you for the valuable comment.

noThank you for the valuable comment.

NO

Thank you for the valuable comment.

No comments

Thank you for the valuable comment.

No

Thank you for the valuable comment.

No

Thank you for the valuable comment.

noThank you for the valuable comment.

No

Thank you for the valuable comment.

b) Are there parameters or limit values you have questions about? Which ones and why?
Feedback received

Comments

NO

Thank you for the valuable comment.

No mayor comments

Thank you for the valuable comment.

noThank you for the valuable comment.

NO

Thank you for the valuable comment.

No comments

Thank you for the valuable comment.

No

Thank you for the valuable comment.

NO

Thank you for the valuable comment.

NO

Thank you for the valuable comment.

noThank you for the valuable comment.

NO

Thank you for the valuable comment.

1.3. Do you have any other questions or comments concerning the
OEKO-TEX® RSL / MRSL?
Feedback received

Comments

NO

Thank you for the valuable comment.

No mayor comments

Thank you for the valuable comment.

noThank you for the valuable comment.

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4

It would be very helpful if there will be a version update list in whichclearly stated with every version what the implanted changes are

We are providing dossiers with new regulations for each standard on anannual base. Please find the new regulation for 2023 under thefollowing link: OEKO-TEX® New regulations 2023

NO

Thank you for the valuable comment.

noThank you for the valuable comment.

noThank you for the valuable comment.

No

Thank you for the valuable comment.

noThank you for the valuable comment.

Testing frequency for recycled should be considered. Especially forpost-consumer recycled (mechanical) textiles.
These raw material inputs will be so different batch to batch that it
seems unlikely that testing 2x per year really provides a protection or
guarantee. There needs to be a robust in-house testing protocol(chemical management protocol makes no sense for recycled materials
as we ourselves do not add chemicals, any chemicals that can a problem
are already there in the feedstock) in addition to OEKO-TEX® to ensure
safety. Also, it seems raw material suppliers cannot get certified(supplier if post-consumer garments to us), why not? This is the firststep for the new chain, how to make sure controls are also i place at thisstage?
Then what does OEKO-TEX® certification say to the industry? Does it
guarantee anything? does it provide any real safety / security also incase of problems or claims? Testing only twice a year means that easily
batches can be sold that have some kind of problem, OEKO-TEX®
certification in that case might bring a false safety to downstream
suppliers. If a problem occurs, who is responsible? Does OEKO-TEX®
bare any responsibility because they have given their stamp of
approval?

Part of the OEKO-TEX® STANDARD 100 certification requirements is
an internal quality assurance of the facility For post-consumer
materials testing through the OEKO-TEX® testing institutes twice ayear is mandatory. In addition, for post-consumer recycled materials it
is the responsibility of the facility to ensure a constant quality of thefibres and to proof that to the OEKO-TEX® testing institutes.
OEKO-TEX® STANDARD 100 stands for “tested for harmful
substances” and therefore safe to use. As mentioned above, theinternal quality control of each facility has the responsibility to ensure a
constant quality. The OEKO-TEX® testing institutes provide additional
external testing to ensure safety and trust. This is supported
additionally by many internal quality assurance mechanisms like control
tests on 25% of the issued certificates, round robin tests, audits, etc.

1.4.1. Have you ever calculated your environmental impact like carbon
footprint or water footprint?
The 142 stakeholders who participated gave the following answers:
Personal carbon footprint

Company carbon footprint

Personal water footprint

Company water footprint

Yes

5

13

4

10

No

46

38

47

41

N/A

90

90

90

90

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1.4.2. How important is carbon and water footprinting for you (and yourbusiness)?
Personal carbon footprint

Company carbon footprint

Personal water footprint

Company water footprint

Not important

2

2

8

6

Hardly important

2

2

12

11

Neutral

4

3

3

3

Important

13

12

2

1

Very important

3

6

1

4

N/A

117

116

115

116

1.4.3. Have a look at our "Impact calculator" - what would be the mostimportant step for you for future development?
Feedback received

Comments

Specific recommendations for actions based on aggregated data.
A whitepaper about the results.

Thank you for the valuable comment. We will take this into
consideration for future developments.

We have several projects to reduce impact, with energy reduction &water efficiency projects. So an impact caclucuator is a useful tool.
It needs to be easy and practicalThank you for the valuable comment.

Creating a standard on chemical usage, soil usage would complete theevaluation in our opinion. Also, the overall environmental footprint
during the product would be very interesting to standardize.

Thank you for the valuable comment. We will take this into
consideration for potential future developments or collaborations.

CO2 footprint

Thank you for the valuable comment. We agree with this aspect.
Therefore, we considered amongst the water usage also the carbon
emissions in the development of the impact Calculator.

For the moment I didn't use it. I have to look for it.

Thank you for the valuable comment. If you are interested in more
information about the Impact Calculator, please follow the link:Your Carbon and Water Footprint (oeko-tex.com)

we are always trying to be involved with the environment andsustainability of the whole supply chain. We are following a very strong
policy.

This sounds great. We support this ambition of continuous supply chain
involvement.

Further improving efficiency. We are a small company, but have big
The Impact Calculator is applicable for any type and size of
ambitions. Maybe a consult if its mandatory for a small company like us. manufacturing facility. The actions to be taken based on the results of
the impact calculator vary from company to company. Therefore,
OEKO-TEX® does not provide specific actions but motivates thecompany to design a corrective action plan with measures that will
benefit our environment and the business of the company.
not yet

Edition 01.2023

If you are interested in more information about the Impact Calculator,
please follow the link:Your Carbon and Water Footprint (oeko-tex.com)

6

We will start with LCA's.

This is great. If you are interested in more information about the Impact
Calculator, please follow the link: Your Carbon and Water Footprint(oeko-tex.com)

noIf you are interested in more information about the Impact Calculator,
please follow the link:Your Carbon and Water Footprint (oeko-tex.com)

didnt look. We have our own calculator tool.

It is great you are already calculating your emissions. Feel free to use
the Impact Calculator. You might find valuable insights in how the
Impact Calculator works. Also feedback for future improvements ishighly appreciated.

to link the emission figures to a made in green productThank you for the valuable comment. We will take this into
consideration for future developments.

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III. Product Development

2.1. OEKO-TEX® RESPONSIBLE BUSINESSa) What do you expect from such a service?
Feedback received

Comments

Global legal compliance (so, NYC law, California laws, all others),
not only EU.

In general, compliance of OEKO-TEX® RESPONSIBLE BUSINESS withcertain national policies or laws cannot be claimed due to legal reasons.
However, we will be able to call out alignment of certain aspects of
OEKO-TEX® RESPONSIBLE BUSINESS with national laws. We will take
into consideration:
German supply chain act
Swiss counterproposal to the Responsible BusinessInitiative UK Slavery Act, 2015 US / NY Fashion
Sustainability and Accountability Act
US / California Transparency in Supply Chains Act
FR Loi de Vigilance

A BETTER CONTROL OF ALL PRODUCTS COMING IN... AN
ASSURANCE OF PURITY...

OEKO-TEX® RESPONSIBLE BUSINESS is not a product related
certification but refers to the implementation of a responsible businessconduct in business activities and processes.

a streamlined platform for assessing human rights and environmental
impact across the supply chain and creating transparency on it for a
consumer

OEKO-TEX® RESPONSIBLE BUSINESS supports compliance withhuman rights and environmental criteria, maps their implementation in
the company's own operations and in the supply chain, and provides
incentives to improve the company's own performance in these areas
through the transparency of the due diligence measures implemented.

To be able to show the efforts that we makeAs the certificate and report transparently reflect the efforts in regard
to human rights and environmental due diligence of a businessenterprise, they can be used to demonstrate the implemented due
diligence.

Promote ethical business

OEKO-TEX® RESPONSIBLE BUSINESS certified companies havecommitted to adhering and respecting the Universal Declaration of
Human Rights as well as contributing to ethical business practices
through the implementation and enforcement of due diligence.

I love the Oeko-Step which provides a transpent overview of the supply
chain with risk management + quality management, which gives you avery good foundation and makes the entire organization transparent

Thank you for the valuable comment.

Concrete information on how to solve issues in the
supply chain.

Part of OEKO-TEX® RESPONSIBLE BUSINESS is the conduction of arisk analysis, which unveils potential of existing human rights andenvironmental risks of the company’s business and its supply chain.

Can it not only be for brands? also further down in the chain?
We also have suppliers that require due dilligence.

OEKO-TEX® RESPONISBLE BUSINESS is specifically designed forbrands, traders and retailers to assess and certify their implemented
human rights and environmental due diligence. We are currently
discussing opportunities to make the standard applicable to further
supply chain actors.

audit to a CoC , audit management , health and saftey audit

OEKO-TEX® RESPONSIBLE BUSINESS reviews human rights andenvironmental due diligence requirements, which include reviewing
responsible business policies, and identifies a number of risks that need
to be avoided, mitigated and stopped.

Edition 01.2023

8b) What challenges do you see with regard to upcoming due diligence legislations?
Topic

Comments

Complience.

In general, compliance of
OEKO-TEX® RESPONSIBLE BUSINESS with national policies or laws
cannot be claimed due to legal reasons. However, we will be able to callout alignment of certain aspects of OEKO-TEX® RESPONSIBLE
BUSINESS with national laws.

A MORE OPEN VIEW OFF ALL PRODUCERS FROM BEGINNING TO
THE END OF THE CYCLE, WHAT ASSURE THE END CUSTUMOR OF A
MORE PURE PRODUCT.

As the certificate and report transparently reflect the efforts in regard
to human rights and environmental due diligence of a businessenterprise, they can be used to demonstrate due diligence efforts to
consumers and customers.

ability of companies to mobilize human and financial resources to set up Due to the systematic and structured approach of
the system and track compliance
OEKO-TEX® RESPONSIBLE BUSINESS, it facilitates the implementationof human rights and environmental due diligence for companies.
However, this new approach requires the revision of management
processes, decision-making, KPI`s and as such requires human andfinancial resources to transform and implement a responsible businessconduct.
The complexity of the textile supply chain.

Thank you for the valuable comment.

A due diligence investigation is a complete overview of all figures, data OEKO-TEX® RESPONSIBLE BUSINESS considers the implementation ofand data of a company, providing a clear picture of the current state of human rights and environmental due diligence. It is a tool that supports
a company. This prevents corpses from coming out, such as debts,
the non-financial reporting on ESG.
ongoing lawsuits or contaminated soil.
Support for the requirements of the germany due diligence law.

Among other regulations and laws, the German supply chain act has
been an important reference for the development of
OEKO-TEX® RESPONSIBLE BUSINESS.

c) Do you see any specific chances or risks for collaborating with existing or potential supply chain partners?
Topic

Comments

The risk that a supplier decides to not be compliment, then creating therisk of not being compliment yourself and loose a certificate which isdifficult to explain to sensitive customers.

To ensure that the OEKO-TEX® RESPONSIBLE BUSINESS certificate
remains valid, annual compliance audits in the company are required.
Therefore, compliance is checked regularly.

NO ....;.... IT BECOMES A MORAL DUTY TO BE OPEN AND
Thank you for the valuable comment.
CONSTRUCTIVE IN ORDER TO PREVENT, FIRST THE CUSTOMER AND
IN GENERAL OUR CLIMATE.
Disclosure of information is always a sensitive point within the supply
chain so a special attention would need to be put into data security and
NDAs. Also, the cost might be an issue when cascaded down to the
supply chain.

Thank you for the valuable comment.

The complexity of the textile supply chain.

Thank you for the valuable comment.

What about confidentiality within supply chains ?

OEKO-TEX® RESPONSIBLE BUSINESS considers the implementation ofhuman rights and environmental due diligence. It is a tool that supports
the non-financial reporting on ESG.

Support for the requirements of the Germany due diligence law.

The compliance with regulations and laws as well as the implementationof human rights and environmental due diligence require cooperationand transparency in the supply chains. OEKO-TEX® RESPONSIBLE

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9

BUSINESS supports transparency and communication within supply
chains.
recycled material suppliers that do not have a robust internal chemical
management and product testing strategy, even if these partners haveoekotex if they do not have these additional processes there is high riskof non compliance and final production being rejected due to issues at

OEKO-TEX® RESPONSIBLE BUSINESS is a management tool to meethuman rights and environmental due diligence requirements for thecompany`s own business practices, the supply chains and wider business
relationships.
Detailed requirements on production conditions are covered by ourfacility certification, OEKO.TEX® STeP.

more trust to the partners while using an exsiting Oektoex audit system

Thank you for the valuable comment.

d) Would you use a complaint mechanism for supply chains provided by OEKO-TEX®? In your view, what would your specificrequirements for such a complaint mechanism be?
Topic

Comments

yes

Thank you for the valuable comment.

noThank you for the valuable comment.

NOT DIRECTLY, IT WILL SCARE PRODUCERS...MORE EFFECTIVEWOULD BE STRONGER AUDITS AND SUPPORT TO AVOID MISTAKESIN THE FUTURE

Thank you for the valuable comment. We agree that audits are a strong
tool to secure quality of the certifications and to prevent risks.

The complexity of the textile supply chain.

Thank you for the valuable comment.

yes, but if the tool's scope is large enough and able to encompass awider scope of materials, not only textiles (with all the inherent socialand environmental risk points).

OEKO-TEX® has an expertise in the textile as well as leather industry.
Therefore, we will not widen the scope of materials.

This goes too far.

Thank you for the comment.

That it is transparent, quick, supported by actual experts, mediation of
escalated problems if needed.

We agree with the importance of the requirements and are considering
them in the development of our complaint mechanism.

noThank you for the valuable comment.

2.2. What information do you find valuable in the label check? Would you
like to see any further information displayed?
Topic

Comments

Click on the product class to see what that means. Instead of just II,
should be something like "II (ok for close skin contact, ages 3+)". Link tothe company's buying guide listing? More consumer friendly descriptionof the scope maybe it could show colors like the MIG info does.

Offering consumer-friendly tools is important to us.
Therefore, we initiated a project to develop the Label Check further.

SOME SMALL RISK ANALYSIS TO ENSURE MORE THE KNOWLEDGE
Thank you for the valuable comment. We will evaluate internally and
TO THE CONSUMER WHAT RISK ALL CHEMICAL / SYNTHETIC
take this into consideration for future developments.
PRODUCTS MENTIONED IN THE CERTIFICATION CAN CAUSE EVEN IF
THEY ARE UNDER TOLERANCE ...
info on type of article, certificate scope are valuable. Additionally, we
would like to see the name of the certificate holder.

Edition 01.2023

Thank you for the valuable comment. We will evaluate internally andtake this into consideration for future developments.

10

The company/owner of the certificate number should be displayed.
We have seen other companies printing our certificate number on theirsamples and products.
The consumer can only see the certificate number is valid however they
can't see it does not belong to the product it is used on.

Thank you for the valuable comment. We will evaluate internally andtake this into consideration for future developments.

Is OK like it is.

Thank you for the valuable comment.

We are approved by oekotex, never got a number or certificate.

Please feel free to get in touch with your OEKO-TEX® institute and ask
for your OEKO-TEX® certificate or label number.

Okay as it is.

Thank you for the valuable comment.

Yes the name of certificate company name.

Based on the preference of the OEKO-TEX® MADE IN GREEN label
owner you can see different information about the producer. Pleasefind more information about our “Permission levels” in chapter 4.3.2 of
our OEKO-TEX® MADE IN GREEN Standard.

The name of the company.

Based on the preference of the OEKO-TEX® MADE IN GREEN label
owner you can see different information about the producer. Pleasefind more information about our “Permission levels” in chapter 4.3.2 of
our OEKO-TEX® MADE IN GREEN Standard.

It's okay the way it is.

Thank you for the valuable comment.

name of cert. holder , in case it is not valid - date when renewal as been
applied forBased on the preference of the OEKO-TEX® MADE IN GREEN label
owner you can see different information about the producer. Pleasefind more information about our “Permission levels” in chapter 4.3.2 of
our OEKO-TEX® MADE IN GREEN Standard.

2.3. OEKO-TEX® MADE IN GREENa) What information is valuable to you in the OEKO-TEX® MADE IN GREEN label check?
Topic

Comments

P.S. The show on map links (within the map icons) seem to go to a map
but not show the locations.

Based on the preference of the OEKO-TEX® MADE IN GREEN label
owner you can see different information about the producer. Pleasefind more information about our “Permission levels” in chapter 4.3.2 of
our OEKO-TEX® MADE IN GREEN Standard.

ALL

Thank you for the valuable comment.

Info on label owner and scope are valuable.

Thank you for the valuable comment.

Supply chain.

Thank you for the valuable comment.

Is OK like it is.

Thank you for the valuable comment.

Validation (or was valid until)
We are a small company, the testing process was very expensive so wedont want to renew every 6 months or.... whats stated. Never got any
info on that part.

Thank you for the valuable comment. We will take this input up and see
how we can make the future label check even more transparent andcustomer friendly.

up to spinning mill is interesting for us

Thank you for the valuable comment.

b) What other types of information would you be interested in to see?

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11

TopicComments

Provision of information of the footprint of theend-productThank you for the valuable comment. We will evaluate internally andtake this into consideration for future developments of the
OEKO-TEX® MADE IN GREEN label check.

Provision of company scores

The company score (OEKO-TEX® STeP scoring) can already be viewed
in the company profile within the
OEKO-TEX® MADE IN GREEN map if permission level 3 is applied.
Please find more information about our “Permission levels” in chapter
4.3.2 of our OEKO-TEX® MADE IN GREEN Standard.

Provision of information about environmental and social conditions of
product manufacturingThank you for the valuable comment. We will evaluate internally andtake this into consideration for future developments of the
OEKO-TEX® MADE IN GREEN label check.

POSSIBILITY OF THE "FOOTPRINT" THAT IS BEEN CREATED OF THE
END PRODUCT

Thank you for the valuable comment. We will evaluate internally andtake this into consideration for future developments of the
OEKO-TEX® MADE IN GREEN label check.

Additionally, we would like to see the score of the company.

The company score (OEKO-TEX® STeP scoring) can already be viewed
in the company profile within the MADE IN GREEN map if permission
level 3 is applied. Please find more information about our “Permission
levels” in chapter 4.3.2 of our OEKO-TEX® MADE IN GREEN Standard.

It's OK.

Thank you for the valuable comment.

production free from harmfull substances or closed area so employees
wont get into contact with the substances
so the products is not only good for the consumer but also for theemployees in the manufacturing.

Thank you for the valuable comment. We will evaluate internally andtake this into consideration for future developments of the
OEKO-TEX® MADE IN GREEN label check.

Some products are approved by OekoTex, but it doesnt provide any
info on the manufacturing process.
none

Edition 01.2023

Thank you for the valuable comment.

12

IV. Future Topics

3.1. Circularitya) What are the main challenges you see regarding circular economy?
Topic

Comments

CREATING A SORT OF SUB VALUATION IN THE USE OF RECYCLED
PRODUCTS

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

availability and cost of recycled and bio-based materials, further
development of the recycling infrastructure.

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

Recycleability of textiles onto which transfers, direct print and emblems We agree with the identified challenges and takes them into
are applied by means of direct silkscreen (plastisol, water based
consideration in business development on Circular Economy.
silkscreen inks), digital print (DTG) or heat sealing.
This appears to be a topic becoming increasingly important for ourcustomers, who need to establish this for their environmental
certifications.
Practically there seems no solution for a problem which pertains mostworkwear in use.
Finding a new use for textiles containing different sources of material.
At the moment, more possibilities are available for apparel, less oralmost none for interior textiles.

Thank you for the valuable comment.

To proof that the recycled content doesn't content dangerous
substances.

This is addressed by our special requirements for recycled materials
within the OEKO-TEX® STANDARD 100 where we have developed astrict test matrix to test for harmful substances.

- Not all current production processes (and equipment) are suitable foruse of recycled materials- Collection of post-consumer waste should be well organised, notfeasible to do this for every company on its own, better to structure
within application domains

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

The complexitiy to create industrial feasible circular products.

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

for us, our basic material. thats a one time use. Maybe in the future thismaterial is made of recycled plastic.

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

To get the complete supply chain on this topic and also to accept that
We agree with the identified challenges and takes them into
this has to come with an cost price increase. Even our biggest customers consideration in business development on Circular Economy.
(retail chain stores) with complete Green goals are not acting in real
live. Still adding to much raw materials such as aluminium in there
products then needed. Waste of materials and money.
Recycled cotton and polyester can not be Oekotex certified. It would begood if it could be tested and be Oekotex certified in the same
certificate as the normal Oekotex certificate .

Both recycled cotton and polyester can be certified according to
OEKO-TEX® STANDARD 100. To be in line with upcoming EU
regulations on substantiated green claims, we ensure transparency inthe textile and leather supply chain. This requires separate certificatesfor conventional and recycled materials to allow consumers andindustry partners to identify which materials are recycled and which
not.

certifying recycled materials, especially post consumer (due to legacy
chemicals and issues that arise from use phase (detergents etc)).

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

technical circulation , building up a system of return at the shops of thecustomers , design/produciton of textiles which can be recyled

We agree with the identified challenges and takes them into
consideration in business development on Circular Economy.

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14b) How could OEKO-TEX® support you and the industry regarding circular economy?
Topic

Comments

Provision of a new list summarizing risks of hazardous components inrecycled materials.

The idea will be taken into consideration and its feasibility will be
discussed internally.

human rights due dilligence in the supply chain , recyled productcertificates must not request that only outshellmaterial is important ,but the generall weight percentage of the material - for example –if filling is 60 % of the article weight it can be delivered under a recyled
oekotex stanard 100 % certificate

The testing of pre- and post-consumer textiles is already possible.
The amount of testing will be determined depending on the source andvariety of articles. Please contact any of our testing institutes if you areinterested in getting articles certified. Here is a link to an overview of
our testing institutes: OEKO-TEX® locations worldwide

extra points could be assigned to companies having a sustainability
strategy with a circularity in it and / or circular projects.

Thank you for the valuable comment. We will consider it in ourdevelopments on Circular Economy.

The industrie needs to be pushed to do better in this respect but is has to We agree with you that the whole industry needs to work together tobe a combined effort through the whole supplychain of workwear from achieve circularity goals. Therefore, we are engaged in various
manufacturers, garment rental, laundry and embellishment producers multi-initiative working groups on Circular Economy.
together.
As it stands now we see that it is almost impossible to recycle costeffective or with keeping the footprint down by avoiding solvent
chemicals for removal of these embellishments
More information on the current possibilities.

We will integrate topics around Circular Economy more and more in ourbusiness development and will inform about the process.

Perhaps the waste could also obtain an oekotex certificate (based upon
oekotex-certificates of the garments before they were waste, or based
upon test results).

Thank you for the valuable comment. We will consider it in ourdevelopments on Circular Economy.

- Oeko-tex could give a clear view on content of materials to recycle. It
could be good to have a kind of checklist per type of product on
hazardous components that make clear what are risks in materials torecycleDue to the variety of materials and chemicals used on them a simple
checklist is not possible. An additional complexity brings time, certain
chemicals have been used in certain time frames in the past until they
were identified as harmful and banned. As it is impossible to know the
production date of recycled garments the risk assigned cannot easily be
determined.

Don't overwhelm the industry with lots of certificates.
We drown in administration.

We have prioritized digitalization to reduce the administrative work andenable faster workflows.

Contact me for better explanation. But it will involve some serious
development and a factory who wants to make this base material.
Maybe we should switch to eco paper (transparant).

Thank you for the valuable comment. We will get in contact with to you
for clarification.

To get more awareness what is needed and this starts with the market
We will closely monitor the developments regarding Circular Economy
leaders in the different segments. Ikea is a perfect example for this.
in the market and will consider it in our business developments.
Not much talking they just do it this should be for every one the minimum
level to start with.
Not have a different certificate for each category, like normal, organic, To be in line with upcoming EU regulations on substantiated green
recycled.
claims, we ensure transparency in the textile and leather supply chain.
This requires separate certificates for conventional and recycledmaterials to allow consumers and industry partners to identify whichmaterials are recycled and which not.
have an open dialogue with industry stakeholders regarding this topic to Stakeholder engagement is highly important for us. Therefore, we arestress test the protocol and give open feedback on the existing protocol. engaged in several multi-stakeholder initiatives and working groups
Mapping out the supply chain and how the protocols can/should be
regarding the topic of Circular Economy.
different along the value chain. Understanding what can be done when
there is a non compliance...which in case of post consumer for sure will
happen in higher frequency.

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3.2. OEKO-TEX® Portfolio and Scopea) Are there any special sectors/products of the textile or leather industry which are not properly covered by the current
product portfolio of OEKO-TEX®?
Topic

Comments

No

Thank you for the valuable comment.

No

Thank you for the valuable comment.

All our products are currently covered by the scope.

Thank you for the valuable comment.

Furniture, computer industry (keyboard / mouse). Have it all day indirect contact with your hands. headsets.

It is already possible to certify such articles. Articles with for example
electronic components like headsets can be certified according to theSpecial Articles supplement. If an article or article group is not listed
there, please send a request to any of our testing institutes.
Here is a link to an overview of our testing institutes:
OEKO-TEX® locations worldwide

application form : wrong classification of for recyleted material acutally mentioned endconsumer waste = pre consumer and industralwaste = post consumer

We have already internal definitions for both terms and are working toa more transparent communication of them in external documents.

b) Where do you see potential / a need for OEKO-TEX® to expand its scope?
Topic

Comments

Recycled and organic materials can be pushed more in the current
certifications.

According to our announcement on new regulations beginning of thisyear we will launch OEKO-TEX® ORGANIC COTTON, a standard fororganic cotton textiles in April 2023.
Recycled materials are tested within the scope of
OEKO-TEX® STANDARD 100.

Furniture, computer industry (keyboard/mouse). Have it all day in direct It is already possible to certify such articles. Articles with for example
contact with your hands. headsets.
electronic components like headsets can be certified according to theSpecial Articles supplement. If an article or article group is not listed
there, please send a request to any of our testing institutes.
Here is a link to an overview of our testing institutes:
OEKO-TEX® locations worldwide
human rights due dilligence in the supply chain , recyled productcertificates must not request that only outshellmaterial is important ,but the generall weight percentage of the material - for example if filling is 60 % of the article weight it can be delivered under a recyled
oekotex stanard 100 % certificate

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In November 2022 we launched OEKO-TEX® RESPONSIBLE BUSINESS,
which is a management certification to meet supply chain due diligencerequirements in the textile and leather industry.
This is already considered in the requirements for recycled materials in
the OEKO-TEX® STANDARD 100 certification. The percentage of themain materials is considered to be relevant to prevent greenwashingand misleading communication.

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